A limited company, registered in the UK or not, has to pay Annual Tax on Enveloped Dwellings on UK residential property ...
The Annual Tax on Enveloped Dwellings (ATED) tax year is 1st April to 31st March and companies must file a return by 30 April for each ATED year during which they held residential property in the United Kingdom.
The company is liable to pay an annual chargeable amount based on the value as of 1st April 2017 or the value at the date it was acquired if later than that.
The annual chargeable amounts usually increase in line with the previous September's consumer price index (CPI). However, in 2015, the government decided to increase the annual chargeable amounts by an additional 50%.
As these property value bands are not index-linked, more and more properties will come within the scope of the ATED and will be liable to more substantial annual charges as time goes on.
Up until 5th April 2019, NRCGT only applied to tax gains realised by non-residents on the disposal of UK residential property (aligned with Annual Tax on Enveloped Dwellings which only applies to UK residential property interests).
From 6th April 2019 this was extended to also tax:
- Gains arising from disposals of UK commercial properties - Disposals of interests in 'property-rich' entities where the non-resident person holds (or has held in the last 2 years) a 25% or greater interest in the company. Property-rich entities include companies that derive 75% or more of its gross asset value from UK property (both residential or commercial).
Rebasing is available to the April 2019 value where the taxable property is only brought into charge for capital gains tax as a result of these new rules.
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